GR L 38141; (May, 1984) (Digest)
G.R. No. L-38141 May 15, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANKISIO ARO, PEDRO LASALA, RODOLFO AVILA and RAFAEL ESCAL0NA, defendants, FRANKISIO ARO and PEDRO LASALA, defendants-appellants.
FACTS
The case involves the killing of inmate Jose Mesina inside the National Penitentiary at Muntinlupa on April 10, 1973. Appellants Frankisio Aro and Pedro Lasala, along with others, were charged with Murder. Prosecution eyewitness Benjamin Gagui, a fellow prisoner, testified that he was inside the Iglesia ni Kristo chapel compound when appellants and Rafael Escalona entered, stating they were seeking vengeance for the deaths of Visayan inmates. When Mesina arrived, Aro suddenly stabbed him. Gagui fled and shouted for help. The autopsy revealed Mesina sustained 17 stab wounds.
During the investigation, both Aro and Lasala executed sworn statements admitting their participation in the stabbing. At trial, however, they recanted these confessions. They denied involvement, claiming they were coerced into giving the statements and that they were falsely implicated by other inmates. They presented defenses of denial and alibi, asserting they were not at the crime scene.
ISSUE
The primary issue is whether the guilt of appellants Frankisio Aro and Pedro Lasala for the crime of Murder was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The trial court correctly relied on the positive and credible eyewitness account of Benjamin Gagui. The Court found his testimony consistent, sincere, and courageous, given the prison context. It was highly improbable for Gagui to falsely testify, as he had no known motive to implicate appellants whom he did not previously know. The defenses of denial and alibi were rightly rejected. Being inmates within the same prison compound, they had the geographical proximity to commit the crime, rendering their alibi weak and uncorroborated.
While some Justices noted the extrajudicial confessions (Exhibits “G” and “M”) were inadmissible for being taken without proper constitutional warnings, the conviction stands firmly on other competent evidence—specifically, Gagui’s eyewitness testimony. The Court also applied the aggravating circumstance of quasi-recidivism under Article 160 of the Revised Penal Code, as both appellants were serving final sentences at the time of the crime—Aro for robbery with homicide and Lasala for robbery. This circumstance mandates the imposition of the maximum period of the penalty. However, for lack of the necessary votes to impose the death penalty, the Court imposed reclusion perpetua. The appellants were ordered to pay indemnity and damages to the heirs of the victim.